The Assistant Secretary who oversaw IBRC and banks in Department of Finance and is still there wants a very confidential non-meeting with your leader to give him some information. Do you want to organise? I'm tied up all evening at family stuff... The guy in Finance in charge to meet Micheal [Martin]. But nobody can know.

Karl Brophy > Colm Keaveney

Don't expose him or even mention who has sent this. He's keen to meet MM. Apparently became increasingly agitated as the week wore on but has no way of speaking out and, I gather, is worried about what will happen his reputation. He's a very good banker and he will know EVERYTHING... And he's expecting a call don't worry.

Four minutes later, another text follows with a profile and mobile phone number for Neil Ryan, the former assistant secretary in the Department of Finance. It was followed by:

C Keaveney > M Martin

A very senior civil servant in Finance wants to have Private discussions with you ASAP

M Martin > C Keaveney

At match give me 30 mins.

C Keaveney > M Martin

Good stuff. Senior CC wants to spill. Understands that DOB and friends about to character attack certain Finance personnel to deflect. Wants to exchange ALL.

C Keaveney > M Martin

Neil Ryan wants to privately blow. He knows absolutely EVERYTHING is increasingly worried about the narrative. He wants to meet you privately. The person who has set this up does not want any referencing as an intermediary. Ryan thinks that fall guys have been set up in the Department to distract.

C Keaveney > K Brophy (the next morning)

First step has happened

In his affidavit, a solicitor with Eames solicitors, Diarmuid O'Comhain, lists the above text exchange between Colm Keaveney, then a TD, and the leader of Fianna Fail, Micheal Martin.

"The texts," says O'Comhain in his affidavit, "are in effect a contemporaneous record by Mr Keaveney of discussions he had with Mr Brophy at that time which he was then relaying to Mr Martin and disclose not only that Mr Brophy was a core part of and directly involved in this scheme, albeit in a clandestine manner, but also that Mr Ryan's intentions were directly related to the plaintiff [O'Brien] and Siteserv. It is of relevance that the texts relating to Mr Ryan were exchanged during a week in which the Siteserv transaction had been the biggest IBRC-related news story.

"A plain reading of the text messages appears to suggest that Mr Brophy, having been told that Mr Ryan wanted to speak out, arranged a meeting to do so with Mr Micheal Martin, TD and leader of Fianna Fail, the main opposition party. Not only did he arrange the meeting but he communicated considerable extra detail to Mr Keaveney about the matter that Mr Ryan wanted to speak to Mr Martin about."

It continues: "The plaintiff's [Denis O'Brien] position [is] that Mr Ryan was seeking to disclose confidential information in relation to the plaintiff's private banking affairs and that Mr Brophy was the intermediary. Although Mr Ryan's position and that of his then employer, the Department of Finance, is that while a meeting occurred between Mr Ryan and Mr Martin, that this meeting did not concern the plaintiff [O'Brien] or companies related to him, this explanation lacks credibility when the [following] texts exchanged between Mr Keaveney and Mr Martin are considered."